Will the EU Restrict the Use of Hazardous Substances in Semiconductor and PV Manufacturing Equipment?

By Heinz Kundert, president, SEMI Europe

A European regulation, Restriction of Hazardous Substances (RoHS), restricts the use of certain hazardous substances in electrical and electronic equipment. Semiconductor and photovoltaic manufacturing equipment (SPME) are currently excluded from the scope of RoHS under the large-scale stationary industrial tool (LSIT) exclusion. This exclusion was retained in the initial proposal for the recast of ROHS by the EU Commission published in December 2008.

However, in October 2009, a draft proposal on ROHS recast by the committee responsible of the EU Parliament was published. This proposal would eliminate the LSIT exclusion that covered SPME.Note that SPME includes equipment used to manufacture semiconductors (integrated circuits), photovoltaics, solid state / LED lighting, microelectrical mechanical systems (MEMS), and flat panel displays (FPD).

Loss of exclusion from RoHS for semiconductor and PV manufacturing equipment is a very serious issue. Including SPME under RoHS will hinder the growth of the European semiconductor and PV industries, negatively impacting businesses and European leadership in green technology development.

Concerned about the impact of these proposed changes, the SEMI RoHS Working Group is advocating for exclusions for all SPME based on two reasons:

No significant environmental risk exists from SPME: RoHS goals would not be enhanced as no significant environmental risk exists from SPME. SPME are installed in very limited numbers and locations, in contrast to consumer products. In addition, most SPME is highly reusable and industry practices ensure appropriate controls against environmental contamination risks.

Reduced competitiveness of the European semiconductor and PV industries: Compliance implementation costs are disproportionately high for SPME as compared to other products currently under the scope of RoHS. SPME is complex with thousands of components procured from a multi-tiered, global supply chain. Demonstrating RoHS conformance would require years of supplier micro-managing for new equipment and would be almost impossible for used equipment. Complying with the current RoHS substance restrictions could shut down equipment supply to Europe until product redesign is completed.

Losing the LSIT exclusion in the EU RoHS legislation would be bad for Europe and for other countries as well. SEMI is urging the European Parliament, Council of Ministers, and European Commission - before they make any changes in scope - to apply a comprehensive and detailed impact assessment to quantify the environmental impacts and administrative costs. This assessment should follow the same approach as the formal review which has already been undertaken to assess the effects of expanding the scope of RoHS to cover medical and monitoring equipment.

SEMI urges members and industry partners, especially those located in Europe, to assist in these advocacy efforts. If you would like to join the efforts of the SEMI RoHS Working Group, please contact me, Heinz Kundert at hkundert@semi.org and/or Sanjay Baliga at sbaliga@semi.org (SEMI EHS Senior Manager).